Polaris Asset Management

Client Disclosure Form

About this form:

This form is designed to fulfill the SEC brochure requirement (Part II of Form ADV), and to inform clients about fees and the services of Polaris Asset Management.


The only fees charged will be for a percentage of assets under management. This will be called the asset management program. Fees for this program will be paid quarterly in arrears at a rate of 3/4% per annum.

Services provided, termination agreement:

The asset management program includes the design, construction, asset allocation, implementation, monitoring, and ongoing management of investment portfolios. Polaris Asset Management LLC will make itself available to clients for any specific questions regarding investment strategy or a particular security held in accounts. Clients will receive monthly or quarterly statements at the broker/dealer’s discretion. Polaris Asset Management and/or Robert Doggett anticipates buying and/or selling many of the same securities that will be bought, sold, or recommended for client accounts, though the suitability of different investments for various clients will doubtless vary according to their objectives and tolerance for risk. The client may cancel this agreement without cause and without penalty at any time.

Types of clients:

Polaris Asset Management will provide investment advice for individuals, families, retirement accounts, Uniform Gifts to Minors accounts, trusts, foundations, charitable organizations, and corporations or partnerships or other business entities. Polaris Asset Management LLC requires each new client or family's aggregate account balance (taxable accounts, trust accounts, retirement accounts) to total $500,000. Polaris Asset Management LLC may waive its minimum balances required in certain cases.

Types of investments:

Polaris Asset Management will offer advice on the following types of investments: over-the-counter securities, securities listed on the New York and American Stock Exchanges, U.S. government securities, interest in private limited partnerships, ADR's (listed shares carrying an interest in securities traded on foreign exchanges), exchange traded funds, and publicly traded limited partnerships.

Methods of analysis and risk of loss:

Polaris Asset Management will rely mainly on fundamental analysis of individual companies, though technical analysis, the companies' history of earnings, acquisitions, stock offerings, and rights offerings may also be considered. Additional factors to be considered in investing in closed-end mutual funds include lifeboat provisions, history of the funds' tender offers and rights offerings, net asset value, portfolio composition, management and custodial fees, and price history. Investing in securities involves risk of loss of capital.

Principal sources of investment information:

Polaris Asset Management will rely on financial publications and newspapers, web sites, corporate filings, outside broker/dealer research, prospectuses, conference calls, and broadcast and electronic news sources.

Investment strategies:

Polaris Asset Management will for the most part use long-term purchases in order to gain tax advantages for clients, though the company may at times use margin transactions, short term purchases, and short sales when such strategies seem appropriate.

Biographical Information:

The firm's principal, Robert Doggett, is a graduate of Brown University and the Graduate School of The University of Washington. He was born in 1951 in Houston, Texas. He has been a private investor for thirty-five years, and taught English and Economics at Lakeside School in Seattle, Washington for twenty-five years. He has served on the boards of The Friends of the University of Washington Libraries and The Seattle Shakespeare Company. He is also an Eagle Scout and a member of Phi Beta Kappa. He is not registered as a broker-dealer.

Other financial industry affiliations:

Robert Doggett does not anticipate having other financial industry activities or affiliations outside of Polaris Asset Management. All fee or profit-sharing arrangements will be fully disclosed to the client. This could change in future if Polaris Asset Management develops an asset relationship with another financial institution, though no relationship of this sort currently exists.  Polaris Asset Management LLC recommends Etrade and Scottrade to its clients because of their low costs.


Custody and prepayment:

Polaris Asset Management will not take custody of client funds, nor will it require prepayment of fees by clients.

Review of accounts:

Reviews of accounts will be conducted on an ongoing basis either in person or by telephone. Polaris Asset Management will make itself available to clients for any specific questions regarding investment strategy or a particular security held in accounts. Clients will receive monthly statements from the broker/dealer where their accounts are held, and these statements will detail cash balances, dividend or margin payments, previous transactions, and other account activity. Privately held limited partnerships will provide the necessary K-1 forms to each client.

Discretionary trading power within accounts:

Polaris Asset Management will have discretion over names of securities to be bought and sold, the number of shares to be bought and sold, the broker/dealer to be used for transactions. Commission rates to be paid by the client will be determined by the broker/dealer. Polaris Asset Management will determine the primary custodian for client assets and will have the authority to transact business on behalf of client accounts. Polaris Asset Management will always strive to keep fees paid by clients to the absolute minimum.

Brokerage Practices

Polaris Asset Management does not receive any products or services (so-called “soft dollar benefits”) in exchange for business from any broker/dealer. Polaris Asset Management does not negotiate lower commissions through “bunches” of trades, and will fully disclose to clients the potential advantages and disadvantages of directing transactions through broker/dealers of their own choice.


Non-assignment Clause

Client contracts cannot be assigned (sold, bartered, or traded) to another party.

Balance Sheet:

Polaris Asset Management does not and does not plan to have custody of client funds or securities. Polaris Asset Management will have broker/dealers deduct fees each quarter for asset management accounts.